Flambeau Compliance Policies

Flambeau Consumer Safety – Certificates of Compliance

Conflict Minerals Policy Statement

As required by the Conflict Minerals provisions under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 Section 1502, Flambeau continues to work proactively with all of our qualified suppliers to ensure our products do not contain any Conflict Minerals.

Flambeau supports the efforts to end human suffering and the environmental impact associated with mining of certain minerals from an area described as the "Conflict Region" located in the eastern portion of the Democratic Republic of Congo (DRC) and surrounding countries. Flambeau is committed to meeting legislative and regulatory requirements that seek to eliminate these issues.

Tracing the origin and chain of custody of "conflict minerals" (tin, tantalum, tungsten and gold) throughout a global supply chain is a complex process. This can only be accomplished with the cooperation and support of a vast number of industries, and public and private stakeholders. Flambeau continues to work proactively with its suppliers, industry groups and other stakeholders to develop and implement policies and systems to reduce the risk of minerals in our supply chain coming from mines that finance or benefit armed groups in the DRC region.

Flambeau does not knowingly procure any product with tin, tantalum, tungsten or gold that originates from the Conflict Region. In addition, we expect our suppliers and their suppliers to acquire minerals only from responsible sources that do not violate labor or human rights.

RoHS Regulation Policy Statement

(Restriction of Hazardous Substances)

This statement confirms that Flambeau Inc. is aware of the requirements of the RoHS directive titled: Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in (EEE) electrical and electronic equipment and subsequent amendments. The sole purpose of this regulation is to address the global issue of consumer electronics waste.

The definition of EEE means equipment which is dependent on electrical currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage not exceeding 1000 Volts for Alternating Current and 1500 Volts for Direct Current.

Flambeau Inc. is a custom manufacturer of injection molded and blow molded parts, components and assemblies using plastic resins as their primary component and is not included within the scope of this regulation.

REACH Regulation Policy Statement

This statement confirms that Flambeau Inc. is aware of the requirements of REACH Regulation (EC) No 1907-2006 of the European Parliament and of the Council of 18 December 2006. As of 12 JAN 2017, the ECHA had identified 173 "candidate" Substances of Very High Concern (SVHC).

It is Flambeau's intention to comply with the requirements of this regulation as it applies to producers of Articles. We continue to work with our suppliers to identify if any SVHC components are contained in the materials procured for use in manufacturing our products.

What is an article?

The meaning of an "article" is defined in Article 3 (3):

Article: means an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition;

The function of an article is determined by the intended use and purpose of the article as this is identified by the supplier of the article. The function is also determined according to the expectations determined by the buyer of the article.

Duty to communicate information about the chemicals in the products to the ECHA applies according to Article 7 of REACH.

Article 7 (1) requires Producers and Importers of products to register with the ECHA chemical substances that are intentionally released from the products during use.

Article 7 (2) requires Producers and Importers of products to notify the ECHA of the content of Substances of Very High Concern (SVHC's) if the concentration of SVHC is above 0.1" weight by weight (w/w) and the total amount put on the EU market by the subject company is more than 1 ton per year.

Future Restricted Phthalates Policy Statement

(DEHP, DBP, BBP & DIBP)

Phthalates are widely used as a plasticizing chemical substance in polyvinyl chloride (PVC) parts.

The above 4 Phthalates¹ have been classified as possible causes of acute toxicity and reproductive toxicity as endocrine disruptors to human health and have been proposed to be prohibited for use by REACH Regulation (European Registration, Evaluation, Authorization and Restriction of Chemicals) rule as "Authorized Substance²" to "Restricted Substance³" on or after April 1, 2019.

Flambeau Inc. is working to identify whether any components or finished goods may contain any of the potentially restricted Phthalates. If any are found to be present, Flambeau will work to eliminate these chemicals.

At this time, we are asking you to help us meet our obligations by providing the information listed on the following pages. Please note that the information will be used only in accordance with the provisions of applicable laws, executive orders, and regulations. Providing this information is voluntary and refusal to so will not result in any adverse treatment. The information you provide will be held in strict confidence except that:

Necessary management and supervisory personnel may be informed to ensure proper placement and to provide reasonable job accommodations;

First aid and safety personnel may be informed to the extent appropriate, if the condition might require emergency treatment; and

Government officials investigating affirmative action program compliance may have access to reported information.

Federal law requires employers to provide reasonable accommodation to qualified individuals with disabilities. Please tell us if you require a reasonable accommodation to apply for a job or to perform your job. Examples of reasonable accommodation include making a change to the application process or work procedures, providing documents in an alternate form, using a sign language interpreter, or using specialized equipment.

Section 503 of the Rehabilitation Act of 1973, as amended. For more information about this form or the equal employment obligations of Federal contractors, visit the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) website at www.dol.gov/ofccp.

PUBLIC BURDEN STATEMENT: According to the Paperwork Reduction Act of 1995 no persons are required to respond to a collection of information unless such collection displays a valid OMB control number. This survey should take about 5 minutes to complete.